For a service to be considered physiotherapy it must be consistent with the legislated definition of physiotherapy found in the Health Professions Act and must be delivered in a manner consistent with the Standards of Practice. You can access a good practice article that went in-depth into what makes physiotherapy, physiotherapy here.
However, there is nothing to prevent you from offering non-physiotherapy services, provided you do not represent those services as physiotherapy. If you have identified a business opportunity or a broader application of your skills that does not constitute physiotherapy and you wish to pursue this business stream, what do you do?
The Issue
The public, patients, and funders can become misinformed or can misunderstand the nature of the services being provided when physiotherapy and non-physiotherapy services are not offered as distinct services.
Over the years, the College has received many questions from physiotherapists asking how to properly separate physiotherapy and non-physiotherapy services. Physiotherapists have a professional responsibility to work within the requirements established in legislation, the Standards of Practice, and Code of Ethical Conduct. Although the College has no role in directing how you manage your business, any non-physiotherapy services must be provided in a way that doesn’t impair your ability to fulfill your professional responsibilities. Consistent with the Dual Practice Standard, it is up to the physiotherapist to create the necessary separation between physiotherapy and non-physiotherapy services.
This article will explore how physiotherapists are expected to manage non-physiotherapy business streams without confusing or misleading patients or the public as to what service they are receiving or paying for.
Preparation is Key
Recognize that there are risks to providing non-physiotherapy services within your practice setting and preparing to provide physiotherapy and non-physiotherapy services as distinct business offerings will reduce the risk of any issues.
Take the time to ensure that you have the structures in place to properly separate your non-physiotherapy business from your physiotherapy practice. Transitioning patients from one business stream to another can pose risks. Therefore, the larger the separation between the two services, the easier it is for the patient to understand when services are and are not physiotherapy.
Communication and Consent
Some of the most common issues the College sees when physiotherapists provide non-PT services arise for unclear communication and communication breakdown. For example, the patient who understood that they were receiving physiotherapy and submitted their receipts to a third-party payer, while the physiotherapist understood that they were providing a non-physiotherapy service.
The physiotherapist is responsible for communicating clearly with patients. Recognize that ongoing informed consent is a key part of this. Patients may start out at your physiotherapy practice for an injury and receive conventional physiotherapy services at the beginning. As they are transitioning out of your care as a physiotherapy patient, they may choose to continue with care that is considered a non-physiotherapy service. When doing so, clear communication of the plan, rationale, and implications of that decision must occur.
Booking and Billing
When it comes to risk, booking and billing are areas of concern. Either the administrative structure, physiotherapist, or patient error can lead to a misunderstanding around how to book or bill for a session which can in turn lead to conflict or unmet expectations. Spend time explaining why non-physiotherapy services may not be covered by extended benefit plans and why patients are not able to claim non-PT services for reimbursement as physiotherapy. And take the time to provide clarity on the process a potential client would take if they wished to pursue either physiotherapy or non-physiotherapy services.
Miscommunication can happen, but the more structure you have within your administrative systems and the more you focus on clear communication, the less likely that miscommunication will happen or lead to a larger issue.
To illustrate how communication consent, booking, and billing can be intertwined and create challenges when providing non-physiotherapy services, consider the scenario of a patient who has been in physiotherapy for several weeks or months rehabilitating from a back injury. Over the course of their recovery, they have become quite sedentary. The patient reports their life is quite hectic, and they approach you after their discharge from physiotherapy to provide them with personal training services.
If you choose to do so, you must clearly communicate the following:
- The patient must be informed of what the transition to non-PT services may mean to their potential funding as well as any other implications the change in services may have on their goals of care.
- Prior to any changes being made, the physiotherapist must obtain consent.
- Upon the transition, the patient and you must both understand that the services can no longer be billed as physiotherapy using your registration number.
The key through all of this is ongoing clear, transparent communication with the patient to avoid any confusion or misrepresentation.
Location
Are you planning to offer non-PT services at the same place you practice physiotherapy or are you planning to have a separate space?
If you have completed your yoga instructor course and choose to work as a yoga instructor out of a yoga studio, there is little risk of the public being confused. However, offering one-on-one yoga instruction within the physiotherapy clinic where you also practice as a physiotherapist can lead to the impression that your yoga instruction is physiotherapy. This would be like providing personal training sessions in your physiotherapy clinic’s gym vs. meeting a personal training client at the local gym. Another practice scenario that has become more frequent in the physiotherapist who works in a fitness facility or gym. The location where physiotherapy services are provided can lead to an increased risk of patients misunderstanding the services they are receiving - physiotherapy or personal training. If a physiotherapist working in a gym environment was providing both personal training and physiotherapy services in that environment, the risk of misunderstanding increases.
It seems obvious that a separate space would make it easier to understand that the non-physiotherapy services differ from the physiotherapy services provided at the physiotherapy clinic, but a separate space may not always be an option. If a physiotherapist is providing physiotherapy and non-physiotherapy services from the same location, they will need to take additional steps to separate physiotherapy and non-physiotherapy services.
Advertising and Promotion
This is an area where physiotherapists need to be explicit and transparent about which services are physiotherapy and which are not. Non-physiotherapy services are advertised separately from your physiotherapy services. When advertising non-physiotherapy services, you must not use your protected title - Physiotherapist, PT or Physical Therapist - you are not working as a physiotherapist when providing or promoting these services.
Although having a shared website or social media platforms for your physiotherapy and non-physiotherapy services may make sense from a business perspective, the College’s perspective is that such combined promotion can lead to confusion and misrepresentation and does not maintain the necessary separation between services. The Dual Practice Standard of Practice requires that you maintain separate advertising for physiotherapy and non-physiotherapy services, and that includes websites, social media, and more traditional advertisements.
Administrative Actions
The Dual Practice Standard of Practice requires that if you are providing non-PT services at your current physiotherapy practice location, you conduct non-physiotherapy business activities on separate days or times from your Physiotherapy services. This can create another level of separation from your physiotherapy practice. Setting up different booking and billing portals for your different services will also create separation. Online booking or having an admin flow chart for when patients call can streamline the process and potentially decrease the risk of confusion for patients navigating your business offerings.
Charting
You are required to keep your charting for physiotherapy services separate from any charting you complete for other non-PT services. You may decide to have two separate charting systems in place to further distinguish between the various services you provide. The minimum requirement is to have either separate charts or to clearly document which service you are providing at any appointment.
Self-referral
Conflict of interest occurs when there is a potential financial gain from steering the patient back to you to provide them with the non-physiotherapy service. For example, you are seeing a patient as a physiotherapist, and you are in the process of discharging them but feel that an overall fitness program or continuation in a yoga class would be beneficial to their overall health. You also provide this service and are confident in your ability to continue to assist this patient. Would you refer them to yourself in your capacity as a strength coach or yoga instructor?
As with managing other potential conflicts of interest related to self-referral leading to financial gain, in this case you should provide a list of trainers or yoga instructors that they can access, and you can include your name among them, but you must give the patient options and you must do so in a way that is free of pressure or coercion. They may still choose you, but it is of their own accord.
Summary
The Dual Practice Standard of Practice outlines many ways in which physiotherapists must manage the various roles they may occupy in the delivery of physiotherapy and non-physiotherapy services. Physiotherapists must adhere to the expectations within the Standards and must also ensure that they are operating within the Code of Ethical Conduct.
Previous articles have discussed what makes a service billable as physiotherapy and this article has provided information for the practitioner seeking to provide non-physiotherapy services in addition to physiotherapy while adhering to the Standards of Practice and Code of Ethical Conduct. If you are considering a dual practice situation and have questions about how to do so in a manner consistent with professional expectations, you can also contact professionalpractice@cpta.ab.ca to discuss your situation.
Original: 09/08/2023, Revised: 01/26/2026
Sean FitzGerald, PT, Practice Advisor
